Comment by the AEF on the government’s attempt to ignore CO2 emissions due to Heathrow 3rd runway

Date added: June 9, 2018

In the final version of the NPS, together with updated versions of the draft of papers and analysis that accompany it, the DfT claims to have implemented 24 out of the 25 recommendations of the Transport Committee, which provided official parliamentary scrutiny of the proposals. But it is hard to spot much change in the final NPS than the earlier version – especially on the key environmental challenges to expansion. The AEF comments that the climate change impact of Heathrow expansion was not even mentioned in Grayling’s statement to the House of Commons. Yet the project is in fact no easier to reconcile with climate change targets now than it was in 2010, when a court ruled that it would be “untenable in law and common sense” for the Government to continue to uphold its policy to build a third runway without showing how this would be compatible with the climate change legislation passed in 2008. While current plans to achieve the Climate Change Act are built around an assumption that aviation emissions will be no higher than 37.5 Mt by 2050, with a 3rd Heathrow runway CO2 emissions nationally would be over 40 Mt, under the DfT’s policy of support for growth at other airports. The Government has just ignored the advice of the Committee on Climate Change.
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The final NPS. And the final chance for MPs to reject it

Jun 8th 2018 (Aviation Environment Federation)

The final version of the NPS, together with updated versions of the draft of papers and analysis that accompany it, was published on Tuesday. In a statement to the House of Commons, the Transport Secretary Chris Grayling set out the Government’s case for expansion, claiming “This government has a clear vision – to build a Britain that is fit for the future”. With little time to consider the new material, a yes/no vote on the NPS will be taken by Parliament in the coming days.

The Government claims to have taken account of the 11,000 responses to its draft NPS consultation, and to have implemented 24 out of the 25 recommendations of the Transport Committee, which provided official parliamentary scrutiny of the proposals. Yet it’s hard to spot much change in the substance of the final policy statement compared to the draft version, and in particular there are no new assurances on the key environmental challenges to expansion.

Silence on climate change

The climate change impact of Heathrow expansion has been given almost no serious consideration so far in the political debate and wasn’t even mentioned in Grayling’s statement to the House of Commons. Yet the project is in fact no easier to reconcile with climate change targets now than it was in 2010, when a court ruled that it would be “untenable in law and common sense” for the Government to continue to uphold its policy to build a third runway without showing how this would be compatible with the climate change legislation passed in 2008.

The Government claims that Heathrow’s emissions in 2050 would be 15.9MtCO2 with two runways and 20.3MtCO2 with three. Quite why the CO2 from the third runway is expected to be lower than from the other two is unclear. (It’s questionable that a new runway can eliminate the additional carbon burnt by planes having to hold before landing since it is anticipated to be full within a few years of opening, and there are no further clues to explain why additional mitigation can only be unlocked with the provision of more capacity.)

All the same, and having taken into account the extent to which Heathrow growth will reduce growth at regional airports, the extra CO2 is enough to push emissions from UK aviation at a national level over the maximum recommended by the Government’s expert advisers, the Committee on Climate Change (CCC). While current plans to achieve the Climate Change Act are built around an assumption that aviation emissions will be no higher than 37.5 Mt by 2050, with expansion emissions nationally would be 39.9 Mt the Government predicts, or over 40 Mt under a policy of support for growth at other airports.

Is that a problem? Surely it’s not so hard to lose those few extra million tonnes?

The Government perhaps likes to give this impression, and when pressed Grayling often makes vague references to biofuels or cleaner aircraft. But the Government has not come up with any policy proposals, either within or alongside the NPS, for how cutting these pesky emissions might be done. While the draft NPS was accompanied by a paper on theoretical carbon abatement options, it was clear that many would be costly, uncertain, or difficult to implement.

The Airports Commission had similarly claimed that it was theoretically possible to expand Heathrow while achieving a ‘carbon cap’ of 37.5 Mt, and their line on this is quoted several times in the NPS. But they never bothered explaining how this would be achieved, saying carbon policies were a matter for Government. Since some growth in aviation could be accommodated under the carbon cap the Commission simply allocated this to a new runway. It kept quiet on the consequences for competing growth at other airports or how restrictions on the use of existing spare capacity at these airports could be imposed.

The CCC too has said – repeatedly – that the Government needs to come up with a policy plan for limiting aviation emissions to 37.5 Mt. In November 2016 the committee wrote to the Government expressing its concern that the NPS should set out the “business case” for Heathrow expansion in a scenario where emissions were limited to this level. The Government has ignored this advice. In fact, the only climate change “condition” included in the NPS is for the airport to put forward acceptable proposals to minimise emissions at the construction stage of the airport. There is no condition relating to emissions from flights, which account for 97% of the emissions.

Isn’t the UN sorting out aviation’s carbon impact?

The EU ETS for aviation has been scaled back for now to cover only flights within the EU (and the future of this arrangement beyond 2021 is unclear). Meanwhile the UN has agreed in principle to set up a carbon offsetting scheme for international aviation emissions (CORSIA). But the scheme will only apply to emissions above 2020 levels, has no long-term goal, let alone one aligned with the Paris Agreement’s temperature targets, and could yet end up allowing in credits scarcely worth the paper they’re written on.

The Government’s assumption that aviation emissions will in future carry a significant carbon price bears no relation to this reality. The cost of reducing a tonne of carbon under CORSIA is estimated to be approximately £11 in 2030. The Government’s 2030 carbon price, assumed in the modelling for aviation emissions, is seven times higher at £77/tCO. Since the carbon cost is assumed to have a dampening effect on aviation demand of around 10% by 2050, the Government’s forecasts probably overstate the likely reduction in CO2 from carbon pricing, and therefore understate the scale of the carbon challenge.

The Committee on Climate Change has, meanwhile, been unequivocal in its advice on this issue: the UK’s Climate Change Act should be achieved through UK action, not offsetting, for us to play our fair part in global efforts to limit dangerous levels of warming.

It’s worth noting too there has been no recognition of the wider climate impacts from aircraft contrails and NOx emission at altitude, an issue that, together with reviewing aviation’s role in the context of delivering the Paris Agreement, can only put downward pressure on the amount of aviation CO2 emissions that can be accommodated under the Climate Change Act in the future.

Other impacts

Meanwhile, our longstanding concerns about risks to air quality from the expansion, and about increases in noise, remain unresolved. Despite the high risk of expansion causing breaches of air quality legislation, the airport itself has been put in charge of managing this risk with no external regulation or enforcement plan in place. And on noise, the Government still proposes a ban on scheduled night flights of just 6½ hours, with no further information on where the flight paths would be so which communities are going to be worst hit.

All for the national interest?

Does the UK economy really need this? The official figure now quoted for the national benefit of the scheme over sixty years has fallen by about two thirds since the Airport Commission’s original assessment, and including costs as well as benefits cuts it to little more than zero. And while many regional airports seem to have been wooed by Heathrow’s talk of more domestic connections, the Government’s own evidence shows that few of these routes are likely to materialise, while almost every airport outside the South East will in fact lose growth as a consequence of Heathrow expansion.